“I firmly believe that an effective, and the best exercise of the dual charter system, is when both charters are pushing each other to match the needs of the American consumer,” he said.

FOM has been an issue of concern for Metsger for some time—“ever since I served on the board of one of my local credit unions, and later when I shepherded modernization of Oregon’s FOM rules through its legislature,” he wrote in a Jan. 8, 2015, op-ed that appeared in Credit Union Times.

Metsger believes FOM can be addressed through regulation and statutory changes.

The NCUA recently formed an internal working group to review the agency’s FOM regulations, and the group is consulting with credit unions and other interested parties on how the NCUA can, under their existing authority, improve federal FOM rules.

In his op-ed, Metsger listed five changes to existing federal FOM rules that could have significant impact:

Allow credit unions converting from single or multiple common bonds to community charters to continue serving select employer groups, even if they are located outside the new community charter boundaries.

Permit the addition of adjacent areas to community charters without requiring them to be in a Census Bureau “Core-Based Statistical Area.”

Eliminate the current requirement that a community charter serve the “core area” of a CSBA.

Revise and simplify the processing for determining that an area is underserved and thus eligible to be added to the FOM of a community charter.

Allow active-duty military personnel and their families to automatically qualify as low-income households.

Metsger noted that other changes to FOM are necessary as well, but they go beyond NCUA’s authority under existing law. Therefore, he said, Congress must pass changes in the statute. And while that task may be difficult, it’s not insurmountable, he said, recalling past changes that were enacted on a bipartisan basis.

NASCUS met with Metsger prior to the CUNA GAC to discuss the FOM issue in more detail and offer support in achieving meaningful reforms. NASCUS President and CEO Lucy Ito applauded the changes he has advocated for on behalf of the NCUA.

“NASCUS welcomes modernization of the federal field-of-membership framework,” Ito said. “As Vice Chairman Metsger noted, Americans’ sense of ‘community’ and their ‘common bonds’ are vastly different today than a generation ago. A consumer’s ‘local’ community, today, is commonly multi-associational, multi-state, or non-geographic. Field-of-membership expansion mirrors the practical reality of life in America, today.”